The complaint, filed Wednesday (July 18) by the Birmingham law firm of White Arnold & Dowd in the 10th Judicial Circuit in Jefferson County, alleges that commissioners violated the state's Open Meetings Act by discussing Pizzato's job performance during a closed executive session. "Because Pizzato is classified as a public employee who is required to file a statement of economic interests with the Alabama Ethics Commission," the suit says, "such a discussion of Pizzato's job performance was prohibited by the Opening Meetings Act."

The suit also reveals that Pizzato's attorneys have been unable to obtain from the commission's attorneys audio recordings and other related materials from the March and June commission meetings. During those meetings, disagreements between Pizzato and commissioners surfaced over religious programming, and commission members imposed a new mission statement for the station. "As a result of our ongoing investigation, we have discovered that commissioners are giving conflicting versions of what happened during the March and June AETC meetings," the document says.

And the complaint seeks to remove commission Chair Ferris Stephens, and void all decisions by the commission since his arrival in 2010, because, it alleges, he is ineligible to serve in that capacity. The suit cites the statue governing the commission, which states that ". . . no member of the commission shall hold any other office . . . " Stephens is an assistant attorney general.